Witness: TF1-388 [On Former Oath]

May it please your Honours, a matter to do with sitting for today and the completion of this witness's testimony. Your Honour, it is the Prosecution's desire that this witness's testimony be completed today. We are grateful to my learned friend on the other side for already having given us an indication as to how long he might be on cross.

Your Honours, the indication is that we might very well finish within sitting time today but, your Honours, you never know and the Prosecution simply intends to request that this Chamber considers sitting beyond the normal time in the event that we have to go beyond normal time to complete the testimony of this witness. Your Honours, the Prosecution anticipates that we should be able to conclude in that event not later than within an hour of normal sitting time.

I want to ask you a few general questions at the moment and then we will look again at some of the matters that you were telling us on Wednesday. When you were living in 2007 and the early months of this year in Sierra Leone, you were living in Tengbeh Town in Freetown, weren't you?

I suggest that's nonsense, Mr Jaward. It was you who said, "I would never reveal my contact with this Court to anybody, especially somebody like Alice", indicating that there was a particular aspect of her personality that made her especially unsuitable to discuss your contact with the Court with. Are you going to tell us what the problem with Alice was, or aren't you?

It's right, is it not, that when you fled with Sam Bockarie into Liberia you became an artillery specialist for the - sorry, when you went with Sam Bockarie to the Ivory Coast you became an artillery specialist for the Ivorian rebels?

Yes. You are expecting to enter into such an agreement not just to pay your further studies, but also to continue your economic and security arrangements. In other words, to continue to provide you with some sort of income and security after you have given your evidence. That's right, isn't it?

Despite the fact that there is no mention of it at all in the interview notes when you were giving them the detailed account of all of those events on 10 August last year. You say that they have missed out your reference to seeing corpses on the ground, do you? Do you understand the question? You say that you told them about seeing corpses on the ground in August of last year, but the fact that there is no mention in their notes of that interview means they omitted to include that detail that you gave them then, yes?

So the two people who are interviewing you, Mr Niemi and the lady you call Madam Brenda, managed to miss that out and you say they didn't read that interview back to you so you had no opportunity to correct their error, yes?

I never condemned that idea that they never read interviews to me, but what I said here was what I confirmed and that was the reality that I knew happened and if there were any changes, I did not know how the changes came about, but what I am saying here in this Court is what I consider the reality and I know is the fact that I am saying.

Mr Jaward, it's complete nonsense that those two people missed out reference to corpses in their notes, isn't it? You gave a different account of these events, I suggest, when you were interviewed in August of last year and you now can't remember the story. Do you agree?

This is what I am saying here. If I had said a particular thing and I believe that that is one of the issues, I mean points or the experience that I had at that time, and that I can remember I had made mention of that, that is what I am saying, that I made mention of that, but that particular conversation interaction at that time that happened I cannot exactly give you the true picture of what happened at that time.

You told us last week when you were giving your evidence-in-chief, that is to say your evidence to my learned friend for the Prosecution - you told us of an occasion when Foday Sankoh's girlfriend Jande was killed. Do you remember that?

Right. Well, you know that I will be corrected if I put something wrongly to you. I suggest that you have never mentioned the killing of Jande in any of these interviews before and I will be corrected if I have missed it. Is the killing of Jande something you heard about when you have been monitoring the trial over the media?

You see, the only thing I can tell you, sir, is that if you continue to say that I have been monitoring I cannot challenge your evidence, but if there is any other Jabaty Jaward who is related to what I have experienced and what I have said here I think you can find ways to prove your allegations against me.

Again I suggest that is totally wrong and I will be corrected if I have missed that particular detail, but I suggest that is something else that you have thrown in during the course of your evidence-in-chief either because somebody has asked you to, or because you have heard other witnesses talk about heads on sticks at checkpoints. Do you agree with that?

I can remember when I even came here before, even before I appeared in court here, the lawyer who was dealing with me at that time, Mr Bangura, I even made mention of that to him. I remember that in my evidence.

Well we have not heard of an interview with Mr Bangura in June, but I am not in a position to dispute that. What I can tell you is that, unless I have missed it, there is no record of you having told that to the Prosecution. Has somebody been encouraging you to give these little bits of evidence which I suggest you have never told the Prosecution before?

You mentioned on Wednesday, or you made reference on Wednesday, to the fact that at the time of the incident when you were almost killed that you talked about "The first time when I was almost executed". Was there a second time?

I can remember that the second time was at the time I was in Ganta when I was instructed by the combat medics, who were working with this Dr Magona that I made mention of, that, you know, since I was with Magona at that particular time they said whenever there was an emergency case the ambulance that used to carry the wounded soldiers to Monrovia at that time when it was not available or would not carry everybody they should use the bus which was there and that he recommended that as a driver I should be assisting in doing that. I was asked at one time to help carry some wounded soldiers to Salala, close to Monrovia, because the instruction was that I was not to enter Monrovia. But whilst doing that, not knowing that Salami, who was one of the wounded soldiers at that time, noticed that I had been sent to carry the wounded towards Monrovia, they said he called and informed Benjamin Yeaten that I was escaping through by that means to go to Monrovia.

So when we left and we got to the same CNC that I have been referring to here, the logging company, to fuel the bus and continue the journey, I saw a pick-up of one of the artillery soldiers who were based in Ganta. They came and arrested me and they said it was by the orders of Benjamin Yeaten and they carried me back to the base. Whilst we were on route, from the discussion the commander heard on the Thuraya phone later they said Jungle asked that they should take me to him. So, when they took me to him first I was jailed and later in the jail Jungle came again and took me from there and back to the combat camp. And even before I could understand the story I have just narrated, that it was Salami who said to Benjamin Yeaten that I was trying to escape, then Benjamin Yeaten instructed them that if I was trying to escape they should arrest me and kill me. So that is the second incident, one of the areas that they attempted to kill me during that incident that I can remember.

Well, you said that somebody noticed you driving the wounded soldiers towards Monrovia and informed Benjamin Yeaten that you were escaping and so they decide to stop you, arrest you and they are going to kill you again, or they are going to attempt again to kill you, yes?

One of the main reasons that I myself gathered was from what happened to the other brothers that he had executed with Sam Bockarie, because he never had wanted me to give the information that I am giving today in relation to Charles Taylor's trial because by then we had heard about the indictment and that things were not to be revealed.

Mr Jaward, on the numbers that you gave us earlier in the week - do you remember when you went through those handwritten lists and gave us the numbers of people who had been killed in order to stop it being found out that they were Sierra Leoneans in the ATU - you listed less than 50 people out of 189.

Yes, sir, those were the people that I can identify by pictures and I knew them before by those names, but the rest of the other people were all involved in that, but I cannot specifically refer to a particular person as a particular individual.

Even allowing for others killed in combat or dying of natural causes and the rest of it, there were still dozens of RUF ATU members still alive, weren't there, from your list that you looked at and ticked off?

Well, I cannot give you the exact statistics of all the categories you are referring to, but what I told you was that the majority of that particular group I believe were all killed because of that particular issue I have made mention of here.

Those were the brothers or friends that were so close to me that I knew and that I can recognise and that I can give account about and not somebody from the group that I had not seen after the incident and I don't have any guaranteed information about his real name to say yes, this is one of them here.

We are going to look in a moment at the names that you ticked off, but before we get to that stage I want to ask you a little more, please, about your friend High Command that you were with in Gbankoi the day before all this happened. That's right, isn't it; the day before you were nearly executed for the first time?

No, sir, as far as Ivory Coast was concerned I only saw High Command when he and Andre who I was referring to, that Felix Doh, went to investigate about the death of one of the bodyguards of Benjamin Yeaten who died during the ceasefire in Ivory Coast.

Did High Command tell you at any time, either when the two of you were in Gbankoi, or later when you saw him in Liberia - did he ever tell you that Sam Bockarie's men continued to cause problems with the Ivorian rebels by beating them up and not taking orders from them?

I'll try it again. At any time in your conversations with High Command did he ever tell you that Sam Bockarie's men were causing problems with the very rebel forces that they were supposed to be fighting with, in other words fighting alongside?

That morning I - we slept together that night we returned from Gbankoi and that morning I was with him until they sent me to take the rice and salt in my jeep when I was arrested. I left him at Benjamin Yeaten's house base at Ganta.

And did he not tell you that after he left you, after the two of you had been to Gbankoi together, that he went off to a meeting with Benjamin Yeaten and Moses Blah and Joe Tuah and some ministers and other commanders to talk about how to deal with Sam Bockarie? Did he not tell you about that, High Command?

I think you have already told us that although you had conversations with High Command he never told you that he was one of a group of ten men who surrounded Sam Bockarie and shot him dead. He never mentioned that to you?

Your Honours, my learned friend is seeking to have the witness establish something of the character of a person and the witness is not in a position - should not be in a position to give that sort of evidence, your Honour.

He has asked - Mr Bangura, counsel has asked did he consider him trustworthy. He can answer that question and, if he cannot answer the question, he can say so. He has not been asked something as an expert. He is entitled to - I consider that counsel is entitled to put that question. Please put the question again, Mr Munyard.

Well, you have told us about events in 2003 in the region of the area of Ganta and thereabouts. When did you next see him after those couple of months there where you would meet and have conversations from time to time?

I am referring to the occasions that you have just told us about. You were, you say, being kept - supposedly secretly kept - away from Monrovia and at the combat camp you met High Command regularly and you had conversations with him. After that period, when did you next see him and where?

When I was brought to Monrovia, within that almost two weeks when I was with Dr Magona, High Command was wounded. He had a bullet wound in his stomach. Dr Magona used to go to treat him right after Benjamin Yeaten's house on the island - Pako Island. I saw him there and we went there once for him to be treated.

Your Honours, I am disturbed by the line of cross-examination again, your Honour, but specifically my learned friend is seeking to get from the witness matters about the credibility of a person. At one stage my learned friend limited the question to "From your dealings with this person" and that in my view could go on, but when my learned friend puts a question in a more general way and more general terms, your Honours, without specifically saying in what context, then he is seeking matters about the credibility of this witness which I submit that the witness is not --

Your Honour, I resile, your Honour, and let's see, but I am a little concerned about the manner in which my learned friend is seeking to establish matters about the credibility of somebody who the witness may very well --

He said "To me" and that is sufficient for my purposes, your Honour. I can move on now. It was the last of my questions on this particular issue, but that was some minutes ago when I asked it originally:

First of all, the order that took us - I mean we, the Sierra Leoneans that were in the ATU - from Liberia to Ivory Coast to meet Sam Bockarie was an order from Charles Taylor, and when I met him finally in Seguela in the Ivory Coast from our discussion about what really brought us to him he mentioned Charles Taylor and before we could leave --

I am going to stop you here for a moment. You are not dealing with the question that I asked you. I asked you if you ever yourself overheard Sam Bockarie in contact with Charles Taylor. Answer that question, please.

This is a handwritten list, not done by you - well, to be strictly accurate it is three handwritten lists and I will ask for all three of them, MFI-9 A, B and C, to be given to the witness. They are all dated 10 March 2002. One is a list of graduates working with the ATU brigade, another is called "Present Graduates on Gbatala Base" and the third one --

"Present Graduates on Gbatala Base" and the third one is a list of brothers working at the motor pool. Although no-one except a handwriting expert should ever say that the handwriting looks the same, on the face of it to the non-expert eye they appear to be written by the same person, do you agree? You have looked at them out of court with the Prosecution. You have looked at them in court and marked them. Do you agree they look as though they are written by the same person?

No, sir, any document I prepared like this I could remember my handwriting. I only said that the names on the first list that was given to me I can remember these names of people with whom I graduated.

This is what I am saying, sir. A battalion had their own organisations and there were other attachments that I cannot remember, all these that make up this battalion. So I cannot really, you know, give you any figure here now that I feel is exactly the truth I'm telling you.

This is what I'm saying. My own company at that particular time, I had to sit down and start checking the company organisation before I can even get to that, but I cannot remember any rough estimate for now.

Mr Jaward, it doesn't involve mathematical ideas. I just want you to go back in your mind's eye to any occasion when your company took part in a parade with the whole of your battalion and give us a rough estimate, from your memory, of how many people there were on that particular occasion in that battalion.

Really I want you to understand that I don't believe in too much speculation. What I do - that this is not the actual truth. I don't believe in guessing. I want when I say it here to back it up with evidence.

I am going to take you through the list that you marked in court and put various names to you and if the first page of MFI-9A can be put on the screen, please. Thank you. We see at number 2 your name Captain Jabaty Jaward, assignment 1st Battalion, C Company commander and that's accurate, isn't it?

And you marked a number of people on there who you say were killed in this campaign against Sam Bockarie's Sierra Leonean ATU members and you marked on that list number 14, Corporal Samuel D Kellie of the 2nd Battalion, didn't you?

The soldiers who were with Salami - I mean the bodyguards who were with Salami, after Samuel Kellie was killed during one of the attacks by one of the - our own forces from - he was shot from his back. Later they confirmed that this was the mission that we who were with Jungle who Jungle rescued, they were given missions to execute us by that means. So he too was killed in that form.

I wonder, Madam President, if I can ask for the original copy - sorry, I am going to avoid using the word "original". The copy that this witness marked out of court before he gave evidence to be put on the screen now and for the benefit of anyone who has the pages it is 00016033, also known as 16033A. I have a copy for Madam Court Officer if she needs it. I think she's ahead of me. Thank you.

Now, Mr Jaward, have a look at number 14 on that list, but just before you do help us with this. When was it that the Prosecution gave you this document out of court for you to mark on it those who you say were killed in this spate of executions by Charles Taylor, or Charles Taylor's men?

I was always presented with an unmarked list for me to mark the list of those who were killed, you know, for the cause of the death of - for the cause of the death of Sam Bockarie, so I always marked - I was always given an unmarked list for me to mark.

What I am trying to understand is if you marked the list on two separate occasions, did you mark some on the first occasion and then did you put more marks on the same list on the second occasion, or have you marked two totally separate sets of lists?

I was not counting to know how many I had marked on the list. They only asked me who in this category were killed, you know, with Sam Bockarie, in line with Sam Bockarie's death, and after marking they would collect the paper. Then on another occasion they will bring another blank - I mean an unmarked sheet and a similar question would be asked for me to do it. I only marked it. I did not check how many people were killed and whom I marked on that particular paper.

No, sir, I was not having any other list to say I had marked it before and it was available when they gave me the other one to mark. I was just given something like an unmarked paper and they will say "Mark this paper ...", you know, "... against all those who you feel who you knew were killed in line with Sam Bockarie."

Right, I don't want there to be any unfairness. On the first occasion that you were given these lists to put marks on was it all the pages that we have been looking at, that is to say the list of graduates which is four pages, the present graduates which is two pages and the brothers at the motor pool which is one page?

So, it wasn't a question of on the first occasion you were given one or more of these lists and on the second occasion you were given a different set of - you were given a different list that you had not marked the first time round. Is that what you are saying?

Right, put the typed list on one side. I just want to establish, so that there is no misunderstanding, on the first occasion when you were given lists to mark were they these three lists: a four page, a two page and a one page handwritten list all dated 10 March 2003 - I am sorry, 2002?

Very well. I don't want there to be any unfairness to the witness and I want it to be clear that, if he was given maybe the first list on the first occasion and the other two on another occasion that that is - I want to establish whether that was what happened, or whether it was the same lists in their entirety on both occasions.

I said the number of pages that were presented to me here that I marked them, these were the same pages that were given to me on the first occasion. On the second occasion, the same thing. The only addition was a typed list that I can recognise was also shown to me on that day.

All right, thank you very much. That is very clear. As far as I am aware we have only ever been supplied with one list of seven pages that you marked and no typed list, but we will concentrate on the handwritten list and number 14, Corporal Samuel Kellie, who you say you were told had been killed after Sam Bockarie --

Yes, it is Corporal Samuel D Kellie, K-E-L-L-I-E, killed you have just told us after Sam Bockarie was killed and you learnt this from the soldiers with Salami. Look at the handwritten list that you marked and to the left-hand side of the number 14 you have written the letter "C", haven't you?

At that particular time I can remember when I was given this - when I was first given this list this indication - they said which soldiers were also killed - I mean died, but not at the time Sam Bockarie was killed at that particular time. That was the time I was giving "C" to those who were killed, but not at the time Sam Bockarie was killed. Later on when I was given the second list they said died - that died during the course of Sam Bockarie's death. That was the time that I made the indication against him that he was killed at that time in Ganta as a sort of master minded mission against - I mean for the same reason of Sam Bockarie's death; he in particular, Samuel Kellie.

Let me see if I got that right. The first time you marked the list you put "C" meaning that he was not killed in connection with Sam Bockarie's murder, but the second time you marked a list you put an "X" against his name indicating that he was one of those who was killed in the wake of Sam Bockarie's murder. Is that what you are saying?

What I mean here, sir, the "C" was the soldiers who died during the time of attacks on the front line, during the time of attacks. That was the time I was giving them "C", but later when I was asked about those who died in the course of - who died because of I mean for the reason of Sam Bockarie's death, that was the time I said this Samuel Kellie died during an attack, but it was at the time that they were master minding for us to be killed by that means in Ganta. It was at that time that he was killed.

Thank you. On the list we are looking at you have not put an "X" against his name. You have put a "C". Are you saying that the next time you were given this list to look at by the Prosecution you then put an "X" against Samuel Kellie's name?

I am not talking about when you were in court doing it this week. I am talking about the second occasion the Prosecution gave you these lists to look at when you marked them again outside court, do you follow?

Turn to the fourth page, please. This is page 16036, or 16036A. In the final quarter of the page we see a number of lines in a handwriting that appears to be different from the handwriting setting out all the names, do you agree?

I can remember him and - he and Kaifala Swaray came at that time and they were arrested. I can remember the two of them at that time. Then after I can remember, you know, Amadu Bockarie, who was a brother to Sam Bockarie. He too was brought there, I mean in Sierra Leone. Then I can remember Lebbie Williams who came to Sierra Leone too before we went to the Ivory Coast. Then I can remember Yayah Conteh. He also came to Sierra Leone before we left for the Ivory Coast.

At that time we were in the ATU. In 2000 they were the first that succeeded in crossing over to Sierra Leone. They said at that time the Sierra Leone government arrested them. They said they brought them to Freetown and they were under detention at the CID.

As I told you earlier, during my first contact with the Prosecution my main mission of going to them was not to reveal every single aspect of what I saw or other individuals in what I experienced, but when I came to understand that there were other factors - I mean facts that they may want to establish, either to guarantee my stay with them, so whenever they asked questions like those I had to work my mind later to say that I had a full knowledge of this particular idea that I have given you before. That was what brought this correction.

Mr Jaward, you had been interviewed many times before this year by the Prosecution. Are you suggesting that the first time you marked this list this year you still weren't telling the Prosecution everything you knew for some reason that may or may not be clear from that answer you have just given us?

This is what I confirmed later that he was later alive. When I was thinking over that particular incident when I knew that I had to - this account I had given here, I had to think over it to see whether these people were all accurate in what I have done.

We were just looking at the list of graduates and we'd looked at Samuel Kellie who, depending on which account of yours we're going on, either died in action before Sam Bockarie was killed, or died as part of the wave of executions of Sam Bockarie's men. Then we looked at Mohamed Sowe, who was dead but is now alive, depending on which version of your lists we're relying on. Now can we have a look, please, at number 34, Corporal Alusine Kamara of the 2nd Battalion. Alive or dead now, Mr Jaward?

Yes, at that particular time I did the marking, but I am still doubtful about him and all of these names you are seeing are not names that I sat down to actually study them. Those I knew very well were those I confirmed.

It is not like a complete guesswork, but I just want to make you understand that a number of people like this who were not directly under my control, I cannot give account of everybody at that time and after that time I have not set eyes on everybody for us to - for me to confirm by now about them in person, and those I have confirmed from relatives or friends and I know their names better before, these are the people I'm confirming about here, those I really said, unless I cannot confirm to whom that particular name belongs. That is why I'm saying that I don't have any idea about them for now.

As far as what I'm saying in this court now is concerned it is not a guesswork that I'm doing, but if this list was given to me at that time and I did not have a complete confirmation about a particular person at that particular time and when I remember I will have to make --

Well, at that particular time I was in doubt whether they were alive or dead and later when I came to know by their nicknames that those nicknames referred to those people, that was when I came to confirm that these particular people were alive for me to mark it here.

At that particular time, Mr Jaward, when you marked the list that we're looking at it was 4, 5 and 6 March of this year, very recently. According to the documents disclosed to us, that was the time when you were presented with this list and asked to mark it. Are you saying that you've been back to Sierra Leone in the meantime and you've run around and found out who is now dead and who is now alive, or is it guesswork again on your part?

No, sir. You know, when this list was presented to me and I recall that there had been a list of us with the Special Court and that I had to give account on all these categories, there were some I only knew by their nicknames, you know, and after the interview I starting recalling the nicknames and then later I knew that this person was referred to by this particular name. That was why when I came back and I saw the name that the nickname I remembered referred to so and so person, and if I knew that at that particular time the person was dead that was definitely what I was trying to produce here. So I would not look at what I've done before and say no, let it just stay like that. So I would have to get a definite account before I say anything about that person.

Just before we go on, can I clarify an answer. In answer to the question about whether they were definitely dead the witness said, "Those nicknames referred to those people and it was when I came to confirm that those particular people were alive for me to mark it here", and I have them marked as dead. I'm a little confused.

All the things I'm saying here is just like, you know, I can say it was not something that I had to go and ask for the person. I am saying what I know and what I experienced before. It is not like I have any source to go around to and ask and ask and to find out what was happening in Liberia or behind the rebel lines, and I'm doing these things to confirm exactly what I experienced, not just to expose myself to other people by saying that this is the investigation I am doing for this particular Court --

And I suggest that that's what you were telling your friends earlier this year when you were back in Sierra Leone; that you were negotiating a continued and continuing economic package. That's right, isn't it?

This was to confirm to you here that, you know, I did not actually confirm about him whether he was alive or dead, but I had not seen him since after that incident and he was with us in Ivory Coast when we came across to Nimba, but I had not really got, you know --

When I came to know that - you know, after making I mean this marking, when I came to know that the boy called Grenade at that time was referred to as Sheku Amara, that was why I confirmed it here that, you know, he was killed.

At that particular time I concluded doing that, because they all came with us to Nimba from Ivory Coast and I had not got any good information about him, whether he was alive or dead, and I have not seen him.

So why did you not only put an "X" against his name, meaning he was killed in the Sam Bockarie executions, but also "Deceased [killed in action]" on the right-hand column? You've got two different versions of his death in March and now you've partially resurrected him. Why the change?

Do you agree that less than a quarter of the names on this list - on whatever tally you gave, whether in March or in evidence or today, less than a quarter of these people were said by you to have been killed around the time of Sam Bockarie's execution or in the executions thereafter?

No, sir. I believe that all - I mean the majority of this particular group were killed with Sam Bockarie, but those I knew in person and that I can identify on pictures in front of me these are the people I have just confirmed about here, but the majority of the people were killed.

Mr Jaward, the judges can see the "X"s, the number of "X"s on the list and the "X"s are the people killed with or after Sam Bockarie because of being affiliated with him. On the list as originally written or marked upon in March it says 46 were killed with Sam Bockarie, or because they were affiliated with him. 46 out of 120 is a small number, isn't it?

Now the second list, please, page 16037A. This is "Present Graduates on Gbatala Base 10th March, 2002", and here we have a list of 53 names and about 80 per cent of those people went to the Ivory Coast with Sam Bockarie to fight, didn't they?

And on that list you originally marked number 2 and number 3, number 20 - sorry, number 2, number 3 and number 20 as killed with Sam Bockarie or because they were affiliated with him. Three out of 53, yes?

I think you might not have understood my point again. This particular total figure here, the orders given to us were that were - and we all left and went to Ivory Coast, but I am not familiar with all these names to say, you know, this particular person belongs to this, because when I saw pictures in this Court I would not want to say that this is the person and then later when you bring the picture to me I will not be able to identify it.

I was doubtful of the name to tell whether Mohamed Larmie - I mean, how do you call it in fact? The way I knew him, you know, at that time, it was whether I could actually confirm it at that particular time.

Page 16039 or 39A, please. Now, this is a list of 16 people in the motor pool. I want to look at the second half of that list, "Brothers in the Motor Pool not on Pay Roll". Can I just ask did you generally refer to your colleagues from Sierra Leone as brothers?

Well I said he was killed at the time Sam Bockarie was killed, and during that time in March when I was marking this particular list that name never came up for me to know that AB we used to commonly know was who was called Ibrahim Bah here.

Thank you, Madam President. I'm going to ask for a further bundle of documents to be handed out to everybody and I'll give Madam Court Officer the full pile. I think there might be slightly more than is necessary:

This document is headed, "Restricted, Headquarters Anti-Terrorist Unit Brigade, Executive Mansion, Monrovia, Liberia, Office of the Deputy Brigade Commander." Do you agree that's what it says on the face of it?

Thank you. Turn over the page to the next page, please. This has, "Breakdown of brigade roster February 2003", and then there's a series of columns, the number of individuals, their rank, personnel, rate, that's rate of pay, and amount of pay and in the first column there's a list of numbers of individual ranks starting with general. Do you agree?

Just before you go on, Mr Munyard, I think you said 16 captains. The list I have says six. Is there a cumulative somewhere that I'm missing. Yes, it's just been pointed out to me. Please ignore what I said.

Well, we'll just go through those boxes. The first box is the brigade, the second box is MOI, the third box is 1st Battalion and the fourth box is 2nd Battalion and then there's a grand total at the bottom of 2,934 personnel. Do you see that?

And this is a roster for February 2003. I want to make it clear, Madam President, that I don't claim that the documents that follow are a full roster. These are the just the pages we've been able to obtain. None of them are numbered, but I will just give a couple of examples. If you include the cover as page 1, if you turn to page 4 it says at the top of that page, "ATU brigade complete and accurate run down roster":

I'm going to ask you, please, to work from the last page because they're not numbered and I'm afraid I take responsibility for not having numbers put on them, but I was concerned that this was produced exactly as we got it. If you start with the very last page --

They were on them already, your Honour, I believe, and they're not on all of them. At the bottom right-hand corner are you talking about? Certainly in mine I can see 20, 21 and the next one's blank. Some of them are numbered and some of them aren't. Would you give me a moment? I'm sorry, Mr Scott has very helpfully pointed out that although I didn't exercise initiative, he did. In photocopying them he's put numbers. The big numbers at the bottom we've put on and so I therefore would like you all to go, please, to page 24, I think it will be. Yes, thank you:

Right, well, he was alive on Monday, but we'll move on from that. Now if you look on the right-hand column under the word "date", there's a whole series of dates that have been written in there in handwriting, aren't there?

Thank you. In the margin in handwriting there are various names. I don't pretend to be able to work out the first one. It could be Nancy, but I wouldn't swear by it. The second one is Kadiatu, isn't it?